Grantek Systems Integration

Understanding Machine Safeguarding and Lockout/Tagout

October 18th 2017

Jeff Winter, CSP, FS Eng.

Director, Safety Practice

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Today’s Speaker: Jeff Winter

BIO:• TUV Certified Functional Safety Engineer (FS Eng)

• Board Certified Safety Professional (CSP)

• Industry speaker and writer

• American Society of Safety Engineers:

– President of Three Rivers Chapter

– Officer of Manufacturing Practice Specialty

• Z244.1 Accredited Standards Committee

• ISA Machine Safety Sub-Committee Chairman

• B11 Accredited Standards Committee

– B11.19 Revision

– B11.20 Revision

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Today’s Agenda

• Lockout/Tagout Vs. Machine Safeguarding

• Applicable Regulations and Standards

• Highlights of the new ANSI/ASSE Z244.1 Standard

• Example application of the standard

• How to move forward

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Common Industry Battles

EH&S Operations

Lockout/Tagout is hindering our production!

Lockout/Tagout is the regulation and the only way to keep people safe!

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What is Machine Safeguarding?

Machine safeguarding is a precautionary

safety feature on equipment comprised of

devices and methods designed to protect

employees from hazards created by the

equipment while working nearby or while

operating equipment.

Simplified Goal: Keep people away

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What are the requirements of Machine Safeguarding?

Part 1910: Occupational Safety and Health Standards

Subpart O: Machinery & Machine Guarding

1910.212: General requirements for all machinery

1910.213: Woodworking machinery requirements

1910.214: Abrasive wheel machinery

1910.215: Cooperage machinery - reserved

1910.216: Mills and Calenders

1910.217: Mechanical power presses

1910.218: Forging machines

1910.219: Mechanical power-transmission apparatus

1910.212: General requirements for all machinery

1910.219: Mechanical power-transmission apparatus

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What is Lockout/Tagout?

"Lockout/Tagout" refers to specific practices

and procedures to safeguard employees

from the unexpected energization or startup

of machinery and equipment, or the release

of hazardous energy during service or

maintenance activities.

Simplified Goal: Remove hazardous energy

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What are the requirements of Lockout/Tagout?

1910.147 establishes minimum performance requirements for controlling hazardous energy. The regulation specifies that employers must establish an energy-control program to ensure that employees isolate machines from their energy sources and render them inoperative before any employee services or maintains them.

Part 1910: Occupational Safety and Health Standards

Subpart J: General Environmental Controls

1910.147: Control of Hazardous Energy

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Lockout/Tagout Vs. Machine Safeguarding

Lockout/Tagout Machine Safeguarding

Protects employees during service and maintenance tasks

Default: Lockout by removing energy

Protects all employees from general hazards, especially during normal operation

Default: Protect Operator by keeping away

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Minor Servicing Exception

Exception to paragraph (a)(2)(ii): Minor tool changes and adjustments, and other minor servicing activities, which take place during normal production operations, are not covered by this standard if they are routine, repetitive, and integral to the use of the equipment for production, provided that the work is performed using alternative measures which provide effective protection (See Subpart O of this Part).

Lockout/Tagout

Two main goals of Machine Safeguarding:• Identify hazards and evaluate risk (ideally

based off their tasks)• Appropriately apply control measures to

protect against the hazards and reduce risks to acceptable levels

Machine Safeguarding

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How does OSHA enforce 1910.147?

CPL 02-00-147:

• Inclusion of guidance on

the minor servicing

exception, specific energy

control procedures,

periodic inspections, and

unexpected energization;

• Inclusion of information and

guidance on Alternative

Methods to Lockout/Tagout

(LOTO)

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How do employers demonstrate compliance?

“Assessment” standards make sure you identify and remediate hazards appropriately. (e.g. ANSI B11.0, ISO 12100, etc.)

“product” standards give you confidence that safety devices and technology are fail safe and designed correctly. (e.g. ISO and IEC Type B2 Standards)

“Application” standards ensures safety devices and technology are applied, installed, and used properly. (e.g. ANSI B11.19, or ISO C-Type Standards)

“Performance” standards ensure each all safety systems (devices connected together) are designed to still work in the event of a failure. (e.g. ISO 13849-1, etc.)

“Validation” standards make sure ALL the pieces were put together properly to ultimately reduce the risk. (e.g. ISO 13849-2)

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ANSI/ASSE Z244.1 History

• First publication 1982, reaffirmed in 1992

• Revised in 2003, reaffirmed in 2008 and

2014

• 2003 revision included major modifications

were around “How to meet 1910.147

regulation.”

• 2016 revision had a 70% increase in

participation from a variety of industries

• 2016 revision published in December of

2016

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ANSI/ASSE Z244.1 Basics

2016 revision presents distinct requirements for controlling hazardous

energy through 3 different approaches:

• Lockout (Primary approach)

• Tagout

• Alternative Methods

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ANSI/ASSE Z244.1 Contents

1) Scope and Purpose

2) References

3) Definitions

4) Responsibilities

5) Design of Machinery/Equipment for the Control of

Hazardous Energy

6) Hazardous Energy Program

7) Control of Hazardous Energy

8) Alternative Methods of Hazardous Energy Control

9) Annexes

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Section 4 - Responsibilities

Notable changes in 2016 revision:

• All suppliers are now required to meet the design

requirements (Section 5)

• Users (employers) now required to obtain equipment

that complies with section 5.

• Users (employers) are responsible for upgrading

non-compliant equipment to be compliant with

section 5.

Actions to Consider• Require Suppliers and OEMS to

follow Z244.1 as part of corporate specifications to ensure all future equipment fits into your program.

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Section 5 – Design Requirements

Notable changes in 2016 revision:

• Risk assessments are now required during the

design phase of a project

• Documentation requirements– Procedures for use of energy isolating devices

– Instructions for tasks requiring partial energization

– Instructions for servicing and maintenance tasks

– Instructions for releasing or controlling stored energy

• Use of warnings (e.g. labels, placards, etc.)

• Control Integration now commensurate with the risk

• Requirements for tamper resistance

Actions to Consider• Evaluate what requirements

are currently specified to suppliers. Do they easily support your current Lockout/Tagout program or conflict? Don’t know?

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Section 6 – Hazardous Energy Control Program

Notable changes in 2016 revision:

• Greater detail in the development of a hazardous

energy control program, including the elements in

each section.

• Addition of a change management program.

• New decision process for the selection of Lockout,

Tagout, and Alternative Methods.

Actions to Consider• How mature is your current

Lockout/Tagout program? Does it even include the option for alternative methods?

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Section 7 – Control of Hazardous Energy

Notable changes in 2016 revision:

• Added elements needed in the development of

procedures

• Verification of isolation has added emphasis on

testing

• Expanded procedures for user-directed

Lockout/Tagout device removal

Actions to Consider• Do your Lockout/Tagout

procedures include all appropriate elements to be best practice? (and compliant)

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Section 8 – Alternative Methods

Notable changes in 2016 revision:

• Before Alternative Methods can be used:– Practicability/justification analysis

– A risk assessment

– Hazard control hierarchy evaluation

– Evaluation of selected alternative method

• Alternative Methods must be designed by qualified

individuals

Actions to Consider• Do you check if your

suppliers and/or designers are certified in functional safety?

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Potential Situations to use Alternative Methods

• Hazardous energy must be present because is required to

perform the task

• Lockout or Tagout is not feasible or practicable

• When a documented risk assessment shows the task can

be performed with acceptable risk

• When inherent hazards (e.g. thermal, radiation, etc.) are

unable to be controlled using Lockout or Tagout

• When energy is required to maintain equipment in a safe

state

• When repetitive cycling of an energy isolation device

compromise the safety function

Identified as part of a Risk Assessment

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Annexes – Industry Best Practices

Actions to Consider• Are any of the suggestions in

the Annex worth turning into requirements for your company (either through your program or your specifications)?

• How do your current templates compare to the examples? Do they capture the same information?

Example LOTO Inspection Form Example Alternative Methods Justification

Example Group Lockout ProgramExample LOTO Procedures

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Building a Program with Z244.1

Lockout/Tagout Program

Machine Safeguarding Program

Safety Specifications

Project Management Processes

Alternative Methods Justification

Task Based Risk Assessment Process

Inspection and Testing of Safeguards

Training & Awareness

Acceptable Methods of Safeguarding

Documentation Requirements

Design & Functional Requirements

Verification & Validation Requirements

Deviations & Exceptions Management

Stage Gates and Approvals

Example Approach for applying a method Maintenance,Cleaning, or Scheduled Servicing

Live work tasks

Lock-out/Tag-outNeed a 2nd Point of

Control and Protective Measure

Operational Safeguards Measures Adequate

By Permit or by trained people

only

Unscheduled & unplanned activities that happen frequently and are considered to be routine, repetitive and integral to the process

Current Safeguarding or Protective MeasuresNo

GuardsFixed

GuardsPresence Sensing Devices

PL A, B, or C

PL E or PL D Protection Devices

Auto Reset

Manual Reset

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Example Application of Z244.1

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STEP 1: Risk Assessment

Task Based Risk Assessment

Hazard Based Risk Assessment

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STEP 2: Risk Reduction Plan

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STEP 2.5: Evaluation of Existing Measures

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STEP 3: Evaluation of Task for Lockout

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STEP 3: Evaluation of Task for Lockout

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STEP 4 & 5: Verification & Validation

Design Verification

Circuit Performance & Architecture Verification

Example Emergency Stop Validation Procedure

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Summary

Rule of Thumb:

The absence of an injury does not mean the

presence of safety. If you don’t have written

documentation explaining how your

machine is safe, then its not safe.

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Questions?